G.R. No. RTJ-14-2394. September 1, 2014.
GEORGE T. CHUA, Complainant, vs. JUDGE FORTUNITO L. MADRONA, Respondent.

FACTS

Complainant George T. Chua, as president of Manila Bay Development Corporation (MBDC), filed an administrative complaint against respondent Judge Fortunito L. Madrona of the Regional Trial Court (RTC), Branch 274, Parañaque City, for manifest partiality, gross misconduct, and gross ignorance of the law. The complaint arose from the judge’s handling of Civil Case No. 11-0060, an action for reformation of contract filed by Uniwide Holdings, Inc. against MBDC. MBDC filed a motion to dismiss the complaint. The RTC denied the motion via an order dated August 1, 2011. MBDC received the order on September 26, 2011, and filed a motion for reconsideration on October 7, 2011. While the motion for reconsideration was pending, Uniwide filed a motion to declare MBDC in default. Without first resolving the motion for reconsideration, Judge Madrona issued an order on December 23, 2011, declaring MBDC in default and deeming its motion for reconsideration moot. The complainant alleged this showed partiality, deprived MBDC of its right to participate, and was contrary to jurisprudence. The complainant also accused the judge of tampering with court minutes by altering an agreed 15-day period for filing a comment to 10 days. The case was referred to the Court of Appeals for investigation, where Associate Justice Noel G. Tijam found that while the judge erred in declaring the motion for reconsideration moot and in declaring MBDC in default, such errors pertained to the exercise of judicial discretion and did not constitute gross ignorance of the law warranting administrative liability. Justice Tijam also noted the irregular practice of preparing and signing court minutes in advance but found no evidence of malicious tampering.

ISSUE

Whether respondent Judge Fortunito L. Madrona is administratively liable for manifest partiality, gross misconduct, and gross ignorance of the law based on his orders and actions in Civil Case No. 11-0060.

RULING

The Supreme Court DISMISSED the administrative complaint for lack of merit. The Court held that a judge cannot be held administratively accountable for acts pertaining to his judicial functions, unless these acts are committed with fraud, dishonesty, corruption, malice, or bad faith. The errors attributed to Judge Madrona—declaring MBDC in default without first resolving its pending motion for reconsideration and deeming that motion moot—involved the exercise of his adjudicative function. While such actions may have been legally erroneous, they did not amount to gross ignorance of the law, as there was no showing that the error was gross or patent, or that it was motivated by bad faith, fraud, malice, or dishonesty. The Court emphasized that administrative liability is not a remedy for correcting judicial errors, which should be addressed through judicial appeals. Regarding the allegation of tampering with court minutes, the Court found the judge’s explanation—that he corrected the minutes using the court’s inherent power to amend its processes to conform to law and justice—to be satisfactory, and noted the irregular practice of preparing minutes in advance but found no malicious intent. The Court adopted Justice Tijam’s recommendation to caution the judge against allowing minutes to be prepared and signed prior to hearings but concluded that no administrative sanction was warranted.